We find it very encouraging that we all appear to agree that establishing viable, sustainable shark populations in the waters of the Great Barrier Reef is a vital goal. As you reconsider the fishery proposals, we would like to suggest several critical improvements to the shark fishery proposals that would increase the likelihood of success.

1. The proposed catch trigger of 700 tons should be lowered.

Shark populations are continuing to collapse in the GBR, indicating that the current catch levels are not sustainable. Independent research (Robbins, et al., 2006) indicates that shark populations in the GBR are continuing to drop precipitously.

The DPI&F has provided no evidence that a catch trigger of 700 tons is sustainable. The DPI&F population ‘assessments’ appear to be based on catch history, not on true population counts. Catch is not a good indicator of total population because fishermen are able to improve effectiveness through skill and technology to increase catch even while population falls.

A catch trigger of 700 tons was not intended to reduce the shark catch. The DPI&F’s Regulatory Impact Statement supporting the proposals states that the proposed catch trigger equals the 2006 catch level of 700 tons. The DPI&F has more recently claimed that the 700 tons catch trigger represents a reduction when compared against 900 tons, the catch level appearing in the 2007 Status Report. If intentions matter, the Impact Statement suggests the true intent of the proposal is to maintain the status quo rather than a serious attempt at reduction.

2. The catch trigger should be changed to a firm quota.

If sustainable shark populations are the objective, then imposing a catch trigger is the wrong policy. When the proposed catch trigger is reached, it does not trigger the cessation of fishing, but the start of a 3-month period to initiate a review, then the period of time for the review to be conducted, and no clear guidance for the review’s outcome. The catch trigger signals to fishermen that the clock is ticking and they should intensify their fishing efforts, rather than forcing a hard stop.

There is nothing enforceable about a catch trigger because it does not ask the fishermen to do anything and provides no penalties.

3. Quotas should be established on a by-species basis

Shark survival and ability to re-populate vary greatly by species.

All shark species that have been identified as vulnerable or endangered should be off-limits to fishing. Under the proposals, only 4 out of the 28 endangered and vulnerable GBR shark species will be protected. All should be protected.

The DPI&F’s own literature, The Queensland East Coast Inshore Fin Fish Fishery Background paper: Sharks and rays, confirms that more than 4 species deserve protection: “Within Australasian and Oceania waters, 10 of the 216 chondrichthyan species assessed are recognised as critically endangered or endangered, and a further 24 recognised as vulnerable. Stock collapses in Australia and overseas over the years have been well documented (Musick 2004)”.

The sharks that are not on the endangered or vulnerable lists should have quotas in proportion to their ability to withstand them.

4. The no-take zone within the GBR must be expanded and fishing gear within fishing zones should be curbed beyond current limits.

Robbins, et. al, indicates that shark populations in the GBR are continuing to collapse:

“Despite increasing fishing pressure, reef shark catches are rarely subject to specific limits, with management approaches typically depending upon no-take marine reserves to maintain populations. Here, we reveal that this approach is failing by documenting an ongoing collapse in two of the most abundant reef shark species on the Great Barrier Reef (Australia). We find an order of magnitude fewer sharks on fished reefs compared to no-entry management zones that encompass only 1% of reefs. No-take zones, which are more difficult to enforce than no-entry zones, offer almost no protection for shark populations. Population viability models of whitetip and gray reef sharks project ongoing steep declines in abundance of 7% and 17% per annum, respectively. These findings indicate that current management of no-take areas is inadequate for protecting reef sharks, even in one of the world's most-well-managed reef ecosystems. Further steps are urgently required for protecting this critical functional group from ecological extinction."

We urge you to expand the no-take zone, and to further limit gill nets and long lines within fishing zones.

5. There should be on-going independent scientific assessment of the health and biodiversity of the GBR.

Whatever fishery policies are eventually established, there should be on-going research, perhaps conducted by the Department of the Environment, to monitor the impact of the fishery. Monitors on boats and reading of catch reports are not sufficient to measure this impact.

We recognize that the number of licenses that allow shark fishing will be lower under this proposal and there are other policies designed to lower incidental shark catch. However, the same boats that are responsible for the current shark catch will be licensed to continue to fish at pre-proposal levels. These proposals lock in the catch level of 2006 when there were no restrictions and are resulting in the collapse of shark populations.

Sharks fishing programs should be much more conservative because of several critical factors:

Sharks cannot reproduce anywhere near as quickly as other fish. They cannot easily recover from persistent aggressive fishing.

Sharks are much more important than other fish in maintaining ecological balance. Research indicates that depletion of sharks can severely and negatively impact the reef ecosystem and cause collapse of important marine species that other fisheries and people rely on.

Living sharks attract much more ecotourism revenue than dead ones bring to the fishery, as economic research indicates.

The shark fishery is non-essential, existing primarily to serve the shark fin industry for a status soup. There is no substantial market for shark meat and much of the meat is sold as by-product while the shark fins are exported.

These wrongheaded shark fishery proposals are protecting a handful of shark fishermen at the expense of the reef and its tourism, the broader marine food ecosystem and its dependent fisheries, and the biodiversity of a World Heritage area. This dedicated shark fishery is also serving as a death knell for the sharks of the GBR.

We are very encouraged that you have come to recognize the importance of providing a second look at these policies. We stand ready to support the strengthening of measures to protect the shark populations in the Great Barrier Reef.